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									                   CITY OF SANTA BARBARA

                                     IPM STRATEGY

                                      Adopted by City Council

                                         January 26, 2004

City of Santa Barbara IPM Strategy        Page 1
                                               TABLE OF CONTENTS

      Preamble .................................................................................................................. 3

I.    Mission Statement.................................................................................................... 3

II.   Purpose.................................................................................................................... 3

III. Definitions ................................................................................................................ 5

IV. Descriptions of Roles and Responsibilities .............................................................. 8

V.    Notification ............................................................................................................. 10

VI. Tiered Materials List and Exemption Process ........................................................ 12

VII. Record Keeping ..................................................................................................... 17

VIII. Training .................................................................................................................. 19

IX. Program Review & Coordination ............................................................................ 20

X.    Public Information .................................................................................................. 21

XI. Reviewing Plans for New Construction and Landscape Projects ........................... 22

XII. Contractors ............................................................................................................ 23

XIII. Precautionary principle........................................................................................... 24

City of Santa Barbara IPM Strategy                       Page 2

On June 17, 2003, the City Council of the City of Santa Barbara adopted a resolution
directing staff to develop an Integrated Pest Management Strategy for all City
Departments. Prior to this event all City Departments were practicing least toxic
measures and IPM principles; however, there was no united City policy creating
consistency of practice throughout the departments. Pesticide use over a ten-year
period (1990-2000) was reduced by half the volume of materials used in a calendar year
in Parks, the Golf Course, and at the Airport. This strategy was developed to provide an
ongoing specific program to further reduce the amount and toxicity of pesticides used
on City property and, where feasible, to eliminate pesticide use in public areas using
alternative methods.

In an effort to allow this program to be the most effective and of the most benefit to the
public, City departments will coordinate their efforts with the County’s IPM efforts to
have policies consistent for all open space and park areas in the region. City
departments will also continue to participate in Regional IPM Coalition efforts and
collaborate with other local agencies facing similar challenges. Other cities that have a
history of quality IPM programming will also be utilized as resources in the development
and implementation of pesticide reduction efforts. Specifically, the City/County of San
Francisco, California, and Seattle, Washington, have extensive IPM programs that offer
models of learning for the City of Santa Barbara.

At the January 26, 2004 City of Santa Barbara, City Council Meeting, Council adopted
the following Integrated Pest Management strategy. Council further directed staff work
toward the goal of having pesticide free parks.

I.       Mission Statement

It is the mission of the City of Santa Barbara IPM Policy to promote environmentally
sensitive pest management while preserving assets and protecting the health and
safety of the public and our employees. All costs and impacts associated with pesticide
use, including community and environmental health, will be considered. The following
IPM Strategy describes the City’s goals and demonstrates how the City will achieve
these goals.

II.      Purpose

The purpose of this IPM Policy is to ensure that the City:

•     Reduces and eliminates the use of pesticide products that pose known, likely, or
      probable human health or environmental risks;
•     Promotes the use of non-hazardous and/or reduced risk alternatives that are
      protective of human health and the environment;

City of Santa Barbara IPM Strategy     Page 3
•   Applies pesticides in a manner that protects and enhances our region’s natural
    resources and public health;
•   Pesticide use is a model of environmental stewardship in the eyes of the public;
•   Maintains a leadership role in developing both ecologically sensitive and
    aesthetically pleasing landscapes and structures;
•   Practices a consistent standard of environmental stewardship by departments
    managing structures, landscapes, and other grounds;
•   Establishes a program where pesticides categorized as toxic or persistent (Tier 1)
    are only used when there is a threat to public health, safety or the environment, or
    when use is warranted to prevent economic damage and only after other alternatives
    have been implemented and shown to be ineffective or considered and found
•   Establishes a clear criteria for pesticide use, to reduce the amount and toxicity of
    pesticides and eliminate pesticide use on City property and where feasible.

This IPM Strategy also provides for periodical re-evaluation of pesticides used by the
City. The Strategy requires updates, which outline pesticides that are being used in all
departments, and will allow employees involved in pesticide use to make conscious
decisions about the control mechanism selected, to employ the of use pesticides wisely,
and to make full use of pesticides purchased. All departments responsible for
overseeing construction projects; managing City-owned structures, grounds,
landscapes; and purchasing and/or using pesticides are affected. In addition, all
contractors that are applying pesticides on the City’s behalf will be required to subscribe
to the IPM Strategy. Disinfectants used to protect human health are excluded from this
strategy and the IPM policy.

City of Santa Barbara IPM Strategy     Page 4
III.    Definitions

A binding written agreement requiring the services of an outside provider for grounds
maintenance or any pest control related services or services that may include pest
control activities.

A person, firm, corporation, or other entity, including a governmental entity, that enters
into a contract with a department.

A pest outbreak that poses an immediate threat to public health or significant economic
or environmental damage.

A process by which materials not on the approved materials list, can temporarily be
used, but only after all alternatives have been reviewed, evaluated, and or implemented
and only after the IPM Committee has authorized the use of the pesticide for the
specified purpose. The application for an exemption shall be filed on a form specified by
the IPM Committee and signed by the IPM Coordinator. Exemptions may be one-time or
programmatic and the decision to approve an exemption will be based upon an
evaluation of the failure of success of alternatives, and taking into consideration public
health, environmental, and financial risks. (See Addendum A)

Hazardous Material-
A chemical or mixture that may pose a physical hazard, health hazard, or environmental
hazard and that is regulated under the law to control its harmful effects. This definition is
not intended to be rigid or legalistic because all materials regulated in this manner merit
special attention and consideration under this program.

IPM Committee-
Oversight Committee consisting of representatives from each City department
designated as the Department’s IPM Coordinator, two Community representatives and
other department representatives as deemed appropriate by individual departments
involved in the IPM strategy implementation. This oversight committee shall be
responsible for guiding the agency-wide implementation of the approved IPM strategy.
The IPM committee shall meet a minimum of four times per year.

IPM Coordinator-
Individual designated for those departments that apply pesticides or contract with
pesticide applicators. The City Administrator may appoint a person to coordinate these
activities on a citywide basis to serve as the primary point of contact. The IPM
coordinator(s) shall be trained in the principles of low risk IPM, safe application of
pesticides, and alternatives to pesticide use.

City of Santa Barbara IPM Strategy      Page 5
The IPM Coordinator shall be responsible for:
1. Coordinating efforts to adopt IPM techniques.
2. Communication with all staff on the goals and guidelines of the program.
3. Coordinating training programs for staff.
4. Facilitating meetings with the IPM Committee.
5. Tracking all pesticide use and ensuring that the information is available to the public.
6. Presenting an annual report to evaluate the progress of the IPM program.
7. Coordinating with other public agencies that are practicing IPM programs.

Integrated Pest Management (IPM)-
A decision-making process for managing pests that uses monitoring to determine pest
levels and tolerance thresholds and combines biological, cultural, physical, and
chemical tools to minimize health, environmental, and financial risks. The method uses
extensive knowledge about pests, such as infestation thresholds, life histories,
environmental requirements, and natural enemies to compliment and facilitate biological
and other natural control of pests. The method uses the least toxic pesticides only as a
last resort and includes the following guiding principles.

1. Monitor each pest ecosystem to determine pest population, size, occurrence, and
   natural enemy population, if present. Identify decisions and practices that could
   affect pest populations. Records of all such monitoring shall be kept.
2. Set threshold and action levels. The threshold level refers to the point where a pest
   problem causes an unacceptable impact. The action level is the level of vegetation
   or pest population at a specific site at which action must be taken to prevent the
   population from reaching the threshold level.
3. Consider a range of potential treatments for the pest problem. Employ non-chemical
   management tactics first. Consider the use of chemicals only as a last resort, select
   and use the least toxic formulation effective against the target pest, and use
   pesticides only in accordance with other provisions of this policy.
4. Monitor treatment to evaluate effectiveness. Such monitoring records shall be kept.
5. Ongoing education of the public.
6. Special circumstances, i.e. protection of botanical specimen, or other mitigating
   factors may allow exemptions to the process outlined above.

Grounds that are actively managed such as parks, plantings, lawns around public
buildings, right-of-ways, watersheds, and open space, etc., excluding large tracts of

Tiered Materials List-
List of pesticides classified into four tiers on the basis of their hazard potential, updated
annually by the IPM Committee. All pesticides considered for use by City departments
are screened through the hazard criteria and will fall into one of the following tiers:

Tier 1: Highest concern

City of Santa Barbara IPM Strategy      Page 6
Tier 2: Moderate concern
Tier 3: Lowest concern
Tier 4: Insufficient information available to assign to above tiers

The Tiered Materials List will constitute the approved list of acceptable materials
required in the IPM Resolution adopted by City Council June 17, 2003.

Pesticide Free Zones–
A site or area within a site so designated as a “Pesticide Free Zone” by specific
departments in order to further reduce and eliminate pesticide use in areas of higher
public exposure or areas with high environmental sensitivity. Any pesticide use deemed
necessary for the protection of public assets, public safety and environment in these
zones will only be authorized through the exemption process.

Any substance, or mixture of substances, used for defoliating plants, regulating plant
growth, or for preventing, destroying, repelling, or mitigating any pest, which may be
detrimental to vegetation, humans, or animals.

Sustainable Design, Construction, and Maintenance-
Principles, materials, and techniques that conserve natural resources and improve
environmental quality throughout the life cycle of the landscape and its surrounding
environment. Sustainable designs for buildings and landscapes incorporate methods
that reduce the potential for pest problems from the start and with long-term
maintenance needs in mind.

Toxicity Category I Pesticide Product-
Any pesticide product that meets United States Environmental Protection Agency
criteria for Toxicity Category I under Section 156.10 of Part 156 of Title 40 of the Code
of Federal Regulations.

Toxicity Category II Pesticide Product-
Any pesticide product that meets United States Environmental Protection Agency
criteria for Toxicity Category II under Section 156.10 of Part 156 of Title 40 of the Code
of Federal Regulations.

City of Santa Barbara IPM Strategy      Page 7
IV.      Descriptions of Roles and Responsibilities

•        Department Head
•        Departmental IPM Coordinator
•        IPM Committee
•        A Governing Body

Department Head

Department Heads shall be responsible for:

1. Ensuring that departmental procedures, budget, and staffing decisions support
   implementation of the IPM Strategy.
2. Providing training to grounds management staff in the requirements of this IPM
3. Designating an Integrated Pest Management Coordinator to ensure products used
   by the Department meet the standards outlined in this IPM Strategy and represents
   the Department on the IPM Committee.
4. At least annually and in conjunction with the IPM Committee, report to the IPM
   governing body on the Department’s implementation of the IPM Strategy.

Establishing an Integrated Pest Management Coordinator

Each department will be responsible for designating an Integrated Pest Management
Coordinator. Departments will be responsible for providing Integrated Pest Management
training in addition to opportunities for the Coordinator and other employees responsible
for pest management.

The Coordinator will be responsible for:

1. Managing the IPM program for the Department.
2. Selecting a location for any IPM pilot project to take place.
3. Reviewing requests for new products to ensure that the products meet the standards
   of the IPM Plan and submitting the product for review to the IPM Committee.
4. Attending meetings of the IPM Committee.
5. Presenting an IPM Annual Report to the Department Head for presentation to the
   governing body on an annual basis.

Annual Report

The report should, as a minimum:

1.    Identify the types of pest problems that the Department has encountered.
2.    Identify the types and quantities of pesticides used by the Department.
3.    Identify the alternatives currently used for phased out pesticides.
4.    Identify the alternatives proposed for adoption within the next 12 months.

City of Santa Barbara IPM Strategy       Page 8
5. Identify any exemptions currently in place and granted during the past year.
6. Identify planned changes to pest management practices.
7. Evaluate the effectiveness of any changes in practice implemented.
8. Discuss any IPM Committee dissentions on any issues

IPM Committee

This advisory committee is responsible for:
1. Meeting on a regular basis to review and discuss pest management practices.
2. Develop, adopt, and periodically review the Tiered Materials List.
3. Review, approve, or deny exemptions to the Phased-Out Pesticide approved List.
4. Review emergency pest control decisions.
5. Prepare the IPM Annual Report.
6. Investigate low-risk/least hazardous alternatives to conventional treatments.
7. Assist departments in implementing the IPM Strategy by developing educational
   information for staff and public users about IPM plans and programs.
8. Annually review the written IPM Strategy and recommend appropriate revisions to
   ensure the program meets the intended purpose and goals of IPM.

The Committee is made up of IPM Coordinators, two Community representatives and
staff involved in the day-to-day operations and oversight of pest management
operations. The Committee’s role is supportive of the IPM Coordinator. Any
dissentions on any decisions should be noted and reported in the IPM Annual Report.

Governing Body

The role of the governing body is to provide direction and support to the departments,
review and commenting on the IPM Annual Report, and considering public input. The
governing body shall consist of the City Council or the Park and Recreation Commission
as assigned by the City Council.

City of Santa Barbara IPM Strategy    Page 9
V.      Notification

(a)     Any department that uses any pesticide shall comply with the following
        notification procedures:
        (1) Signs shall be posted at least two working days before application of the
        pesticide product and remain posted at least three working days after application
        of the pesticide.
        (2) Signs shall be posted at every entry point where the pesticide is applied if
        the pesticide is applied in an enclosed area, and in highly visible locations, signs
        will be posted around the perimeter of the area where the pesticide is applied if
        the pesticide is applied in an open area.
        (3) Signs shall be of standardized designs that are easily recognizable to the
        public and workers. (See Addendum B)
        (4) Signs shall contain the name and active ingredient of the pesticide product,
        the target pest, the date of pesticide use, the signal word indicating the toxicity
        category of the pesticide product, and the name and contact number for the
        Department responsible for the application. (See Addendum B for sample sign)
        (5) Signs will be bilingual in English and Spanish.
        (6) Individual copies of posted signs shall be retained for record keeping
        purposes for one year.

(b)     Departments shall not be required to post signs in right-of-way locations where
        public use and potential exposure is limited or on the airfield areas at the Santa
        Barbara Municipal Airport where public access is restricted. However, each
        department that uses pesticides in such locations, where the use of those
        pesticides is not posted, shall develop and maintain a public access telephone
        number or web site with information regarding pesticide applications in these
        areas. Information will be readily available by calling the public access number or
        accessing the web site. Information shall remain on the web site on all pesticides
        that will be applied within the next three days or have been applied within the last
        four days. In addition, a description of the area of the pesticide application, the
        name and active ingredient of the pesticide product, the target pest, the date of
        pesticide use, the signal word indicating the toxicity category of the pesticide
        product, and the name and contact number for the City department responsible
        for the application will also be listed. Information about the public access
        telephone number shall be posted in a public location at the Department's main
        office building.

(c)     Posting for pesticide use at the Santa Barbara Golf Club shall consist of signs
        placed at the first and tenth tee and in the Pro Shop.

(d)     Pesticide Free Zones established by each department will require a fourteen-day
        advance posting in the event an exemption is approved by the IPM Committee or
        Coordinator and shall remain in place three days after the application.

City of Santa Barbara IPM Strategy      Page 10
(e)     Departments may obtain authorization from the Committee to apply a pesticide
        without providing a two-day advance notification in the event of a public health
        emergency or to comply with worker safety requirements. Signs meeting the
        requirements of Subsection (a)(2) through Subsection (a)(4) shall be posted at
        the time of application and remain posted four days following the application.
        (See section VI C)

(f)     The Committee may grant exemptions to the notification requirements for one-
        time pesticide uses and may authorize permanent changes in the way City
        departments notify the public about pesticide use in specific circumstances, upon
        a finding that good cause exists to allow an exemption to the notification
        requirements. Prior to granting an exemption pursuant to this subsection, the
        Department requesting the exemption shall identify specific situations in which it
        is not possible to comply with the notification requirements and propose
        alternative notification procedures. The Committee shall review and approve the
        alternative notification procedures.

(g)     Departments are responsible for making pesticide use information available to
        staff and the public upon request. Each department shall maintain a list of all
        materials applied on a site-specific basis. This list shall be available at each
        department’s main offices or made available to the public upon request.

City of Santa Barbara IPM Strategy     Page 11
VI.      Tiered Materials List and Exemption Process

The IPM Committee shall develop a tiered risk assessment of pesticides. A prioritized
list of materials will be developed to identify materials that may be targeted for future
phase-out based on IPM Committee review of the product’s contents, precautions, need
for the product, and adverse health and environmental effects. The IPM Committee will
make product recommendations and establish and prioritize the Tiered Materials List for
future materials phase out. The lists shall be submitted as part of the annual report to
the City Council and Park and Recreation Commission. A material on the Phased-Out
Pesticides List may be used if determined appropriate by the IPM Committee in
compliance with the emergency exemption process.

Criteria for developing materials lists shall be based on acute and chronic toxicity of
products and chemicals known to cause cancer and known to cause reproductive
toxicity. Environmental impacts of the products shall also be considered. The approved
materials list shall screen pesticides for the following risk parameters:

A. Acute Toxicity: The potential for a pesticide to cause immediate harm.

1. Hazard Category

Each pesticide product registered by EPA is assigned hazard category I, II, III, or IV by
the Agency based on characteristics of the full product formulation, including acute
toxicity, and skin and eye irritation. In evaluating the acute data, EPA assigns the
hazard category based on the greatest hazard, i.e. ingestion, inhalation, skin
absorption, eye irritation, etc.

The table below shows the toxicity ranges that apply for each category. (Note: LD50
indicates lethal dose 50%; LC50 indicates lethal concentration 50%.) A relatively non-
toxic product (via ingestion, inhalation, or skin absorption) could be placed in the highest
hazard category merely on the basis of extreme eye irritation. Products in category I
are most hazardous and bear the signal word DANGER on their labels. Those in
category II are labeled WARNING. Both category III and IV products are labeled with
CAUTION. Product category was determined from label signal words, and category III
and IV products were not distinguished from each other.

EPA Category             I                II                   III                   IV
Signal Word              DANGER           WARNING              CAUTION               CAUTION
Oral LD50      (mg/kg    Less than 50     Between              Between               More than
body wt)                                  50 and 500           500 and 5000          500
Inhalation LC50          Less than 0.2    Between              Between               More than
(mg/liter air)                            0.2 and 2            2 and 20              20
Dermal LD50 (mg/kg       Less than 200    Between              Between               More than
body wt)                                  200 and 2,000        2,000 and 20,000      20,000
Eye Effects:             Corrosive        Severe irritation    Moderate irritation   No irritation
                         Non-reversible   Reversible opacity   No opacity
                         opacity          Persisting 7 days    Reversible 7 days
Skin Effects:            Corrosive        Severe irritation    Moderate irritation   Mild irritation

City of Santa Barbara IPM Strategy        Page 12
2. Restricted Use Pesticides

Some pesticides are restricted for use by the state to only certified pesticide applicators
and are not available to the general public because of high toxicity, particularly
hazardous ingredients, or environmental hazards.

B. Chronic Toxicity: The ability of the pesticide to cause long lasting harm.

1. Carcinogens (active ingredients only)

For the purposes of the City of Santa Barbara IPM Strategy, this will include all
pesticides on the State of California Environmental Protection Agency Office of
Environmental Health Hazard Assessment Safe Drinking Water and Toxic Enforcement
Act of 1986 list of Chemicals Known to the State to Cause Cancer or Reproductive

2. Reproductive/Developmental Toxicants (active ingredients only)

“Chemicals known to the State of California to cause cancer or reproductive toxicity."
The source used for the development of the Materials Phase-Out List is the State of
California Environmental Protection Agency Office of Environmental Health Hazard
Assessment Safe Drinking Water and Toxic Enforcement Act of 1986 list of Chemicals
Known to the State to Cause Cancer or Reproductive Toxicity.

3. Endocrine Disruptors (active ingredients only)

These are pesticides with the ability to mimic or block the effects of hormones in
humans and other wildlife. Because of the similarity of the endocrine system across
many species, its critical role in development and reproduction, and its extreme
sensitivity to very low levels of hormone-like compounds, there is the potential for
endocrine disrupting substances in the environment to adversely affect wildlife and

Although the science is relatively new and in many cases highly controversial,
considerable evidence of effects in wildlife and some evidence in humans has caused
many scientists to warn of potential dangers from exposure to endocrine disrupting
chemicals. Under the Food Quality Protection Act, the EPA is required to screen
pesticide ingredients for endocrine system effects. Until that screening is done, a
comprehensive list of endocrine disruptors will not be available.

For the purpose of this strategy development, the source used for the development of
the Tiered Materials List is the State of Illinois Environmental Protection Agency list of
known, probable, or suspected of causing endocrine system effects (Illinois EPA
Endocrine Disruptors Strategy, February 1997.).

4. Ecotoxicity (active ingredients only)

City of Santa Barbara IPM Strategy    Page 13
Based upon the required precautionary statements on product labels, pesticides that
warn of potential toxicity to non-target wildlife species will be considered in the
development of the Tiered Materials List. Of primary concern is toxicity to:
• Birds
• Aquatic Organisms
• Bees
• Other wildlife or domestic animals

5. Persistence

Pesticides are considered to be persistent if their half-lives exceed 100 days. For the
purposes of the approved materials list, the Oregon State University Extension
Pesticide Properties Database, the Agricultural Research Service/US Department of
Agriculture Pesticide Properties Database or Hazardous Substances Databank will be
used in that priority.

6. Water Pollution Hazard (active ingredients only):

•   Leaching potential
•   Runoff potential

The Ground Water Ubiquity Score (GUS) index is used to identify those pesticides that
have a high potential to contaminate the ground water.

Ranking by Tiers

Materials will be classified into tiers on the basis of their hazards.

Tier Definitions

Tier 1: Highest concern
Tier 2: Moderate concern
Tier 3: Lowest concern
Tier 4: Insufficient information available to assign to the above tiers

The criteria for assigning materials to tiers are as follows:

Tier 1: (Any of the following are true)

•   Products in EPA Hazard Category 1, Signal Word DANGER
•   Restricted use pesticides
•   Products with known, likely, or probable carcinogens as active ingredients (EPA list
    of Chemicals Evaluated for Carcinogenic Potential classified as Carcinogenic To
    Humans, and Likely To Be Carcinogenic To Humans)
•   Products with reproductive toxicants as active ingredients (CA Prop 65 list)

City of Santa Barbara IPM Strategy        Page 14
•   Products with known or probable endocrine disrupters as active ingredients
•   Products labeled as highly toxic or extremely toxic to birds, aquatic species, bees, or
•   Products with active ingredients with soil half lives greater than 100 days (not
    applicable to products used only indoors on to products used in bait stations)
•   Products with active ingredients with mobility ratings high or very high or with
    specific label warnings about groundwater hazard (Not applicable to products used
    only indoors on to products used in bait stations)
•   Products containing the rodenticides brodifacoum, bromethalin, or bromadionone

Tier 2:

•   All products not assigned to Tier 1 or Tier 3

Tier 3: (All of the following are true)

•   Product contains no known, likely, or probable carcinogens
•   Product contains no reproductive toxicants (CA Prop 65 list)
•   Product contains no ingredients listed by Illinois EPA as known, probable, or suspect
    endocrine disrupters
•   Active ingredients has soil half-life of thirty days or less
•   Product is labeled as not toxic to fish, birds, bees, wildlife, or domestic animals

Tier 4: Not enough information

The Tier 1 list of pesticides will be used by the IPM Committee to determine future
product elimination.

C. Emergency exemption

A department may apply to the IPM Committee for an emergency exemption in the
event that an emergency pest outbreak poses an immediate threat to public health or
significant economic damage will result from failure to use a pesticide that has been
placed on the Phased-Out Pesticide List. An application for an exemption shall be filed
on a form specified by the IPM Committee. (See Addendum A) The IPM Committee
shall respond to the application in a timely manner. If the requesting department is
unable to reach the IPM Committee, the IPM Coordinator may authorize the one-time
emergency use of the required pesticide. The IPM Coordinator must notify the IPM
Committee members of the determination to use the pesticide prior to its application in
the event that the IPM Coordinator is unable to make the request at the IPM Committee
meeting. The IPM Committee will review the circumstances of the emergency permit
issued by the IPM Coordinator at the next scheduled IPM Committee meeting. Signs
shall be posted at the time of application and remain posted four days following the
application. The IPM Committee may impose additional conditions for emergency

City of Santa Barbara IPM Strategy        Page 15
D. Establishing “Pesticide Free Zones”

Pesticide Free Zones are sites or areas within a site established to be free of pesticide
applications. All pesticide applications will be done only through the exemption process.
These zones will be posted with permanent signage indicating them as pesticide free
zones. The following have been established as Pesticide Free Zones.

•    Playgrounds – No pesticides will be applied within 100 feet of playgrounds.
•    Picnic Areas – No pesticides will be applied within twenty-five feet of picnic
•    Alice Keck Park Memorial Gardens – The entire park will be a Pesticide Free
     Zone. This will be a demonstration garden for the community for the use of
     alternatives to pesticides. Sustainable landscape management practices will be
•    Chase Palm Park – All turf areas will be considered Pesticide Free Zones on both
     sides of Cabrillo Boulevard.
•    Shoreline Park – The entire park will be considered a Pesticide Free Zone.
•    Oak Park – The entire park will be considered a Pesticide Free Zone.
•    Alameda Park – Entire block of East and West Alameda Park will be considered a
     Pesticide Free Zone.
•    The following Neighborhood Parks:

     o    Willowglen Park
     o    Los Robles Park
     o    Hilda Ray Park
     o    Sunflower Park
     o    Parque De Los Niños
     o    Eastside Neighborhood Park
     o    Escondido Park
     o    La Mesa Park
     o    Stevens Park

•    Creeks – Within twenty feet of the top of banks in any creek or wetland.
•    Douglas Family Preserve –No pesticides will be applied. Habitat restoration
     projects will require justification of herbicide use through the exemption process
     with an extra step of review by the Douglas Family Preserve Advisory Committee.

The IPM Committee will base decisions to add to the list of Pesticide Free Zones upon
monitoring the effectiveness of alternatives and other factors. It is the intention over
time to expand these zones as time and resources allow.

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E. Timetable for phase out of materials

This Strategy commits the City departments to the following timetable to reduce and
eliminate pesticide usage on public sites.

By January 1, 2004

•      Eliminate the use of all EPA Hazard Category 1 materials
•      Eliminate pesticides listed by the State of California Environmental Protection
       Agency Office Prop. 65 chemicals known to cause cancer or reproductive toxicity
•      Eliminate pesticides on the EPA Chemicals Evaluated for Carcinogenic Potential list
       of pesticides that are Carcinogenic to Humans and Likely to be Carcinogenic to
•      Eliminate pesticides categorized as known or probable endocrine disruptors by the
       State of Illinois.

By April 1, 2004

    •    Develop the Tiered Materials List.

By July 1, 2004

    •    Develop a list of pesticides for elimination on the Tier One list and or best
         management practices for the use of those to remain on the approved materials

By December 31, 2004

    •    Develop “Zone Concept” of pesticide use tied to the Tiered Materials List to limit
         pesticide use based upon potential human exposure.
    •    Determine additional sites as “Pesticide Free Zones”.

VII.     Record Keeping

         (a) Each department that uses pesticides shall keep records of all pest
             management activities. Each record shall include the following information:

             (1) The target pest;
             (2) The type and quantity of pesticide used;
             (3) The specific location of the pesticide application;
             (4) The date the pesticide was used;
             (5) The name of the pesticide applicator;
             (6) The application equipment used
             (7) Prevention and other non-chemical methods of control used;

City of Santa Barbara IPM Strategy      Page 17
             (8) Experimental efforts; and
             (9) Exemptions granted for that application.

        (b) Each department that uses pesticides shall maintain a pest management
            record as a part of their individual departments Integrated Pest Management
            Strategy and provide it to the governing body when requested. A summary
            of record keeping results will be included in the IPM Annual Report.

        (c) Pest management records shall be made readily available to the public upon

City of Santa Barbara IPM Strategy      Page 18
VIII.     Training

Increasing knowledge of staff and contractors who design and maintain buildings and
landscapes is critical to the success of the IPM Program. Consequently, providing
ongoing training and educational opportunities to City staff and contractors regarding
building and landscape IPM concepts, practices, and products will be a priority.

The IPM Coordinator shall invite speakers and arrange for other educational
opportunities to assist departments in implementing the IPM Program each year.
Department Directors shall ensure that IPM Coordinators inform employees on
departmental policies and procedures relevant to this IPM Program and keep staff
current with best landscape-management practices and technologies that utilize
Integrated Pest Management. Department Directors shall also support employee
involvement in identifying and implementing strategies to minimize the use of pesticides
and in evaluating replacements to chemicals targeted for phase-out.

•       All staff associated with planning, design, construction, and maintenance of
        buildings and landscapes shall receive an orientation to the IPM Strategy and their
        roles and responsibilities in implementing it in a written or verbal format.
•       All personnel involved in pest management activities shall receive training on:

        o An orientation to the IPM Strategy.
        o Identification and lifecycles of typical southern California pests, weeds and
          beneficial insects; determining threshold levels for different types of landscapes;
          monitoring techniques; and strategies for successful management of these
        o Noxious weed identification, control, and regulations
        o Pesticide laws and safety
        o Specific best management practices as appropriate

Training will be provided by City/County staff, IPM consultants, IPM technical advisors,
and invited guest speakers. The IPM Coordinator, with assistance from the IPM
Committee, will schedule training. Training and educational opportunities, both formal
and informal, will also occur at landscape staff meetings. Managers and supervisors
are not only expected to participate in the training, but to fully support involvement of
their staff and contractors in the training.

In making landscaping staffing and budget decisions, departments shall consider the
potential environmental tradeoffs; for example, will reduced staffing require increased
use of pesticides to maintain the landscape at the same standard? Will short-term IPM
expenditures result in long-term savings?

City of Santa Barbara IPM Strategy       Page 19
IX.     Program Review & Coordination

Tracking Progress and Evaluating the Program

Annually, the Committee will gather information for the Annual IPM Report. Each
department will submit a summary of the previous year's pilot projects, a timeline for
implementing pilot project recommendations and viable changes at other sites, and
plans for any new pilot projects including changes that can be implemented in the next
fiscal year and a timeline for their implementation. Pilot projects will also evaluate costs
and cost savings.         The Committee shall compile this information and any
recommendations for future direction of the program and shall submit the report to the
Park and Recreation Commission and City Council.

City of Santa Barbara IPM Strategy     Page 20
X.      Public Information

Efforts will be made to educate the public about reduced risk pest management goals
and practices implemented under this policy in the most effective manner given time
and budget constraints. Various venues may be utilized for public education and
information including:
    • Departmental web pages
    • Water bill inserts
    • Public workshops/symposiums and sustainable park sites
    • Articles in City publications
    • Sharing of IPM information with the Community Development Department
       Planning Division in regards to this IPM Strategy, pesticide usage and

City of Santa Barbara IPM Strategy   Page 21
XI.      Reviewing Plans for New Construction and Landscape Projects

Poorly planned landscape designs may require intensive maintenance and greater
reliance on pesticides for pest control than landscapes created with integrated pest
management design specifications.

Departments participating in a City project that includes the design of new landscape or
renovation of an existing one shall design and construct the project consistent with IPM
design specifications. The IPM Coordinator for each department will review all project
plans to ensure that, where possible, the design considers IPM measures and the
following strategies.

In planning, designing, and installing landscape owned and managed by the City, site
objectives shall include future management and maintenance practices that protect and
enhance natural ecosystems. A landscape, facility, or road right-of-way should be
planned and designed taking into account parameters that will enhance the intended
use of the land and minimize pest problems. Design will take into account such factors
as types of uses, soils, grading and slope, water table, drainage, proximity to sensitive
areas, selection of vegetation, and vector control issues. City grounds designers,
planners, managers, crews, and their contractors shall give priority to IPM strategies
when designing new and renovating existing landscaped areas. These include:

•     Using proper soil preparation and amendment
•     Specifying weed-free soil amendments
•     Using mulches to control weeds, conserve water, and build healthy, biologically
      diverse soils
•     Use weed control fabrics under organic mulches
•     Use site adapted and pest resistant plants: “the right plant for the right place”
•     Group together plants with similar horticultural needs
•     Retain and use regionally native trees, shrubs, and perennials where appropriate,
      preferably from genetic stock
•     Pre-plant control of noxious weeds and invasive, non-native plant species
•     Plant for erosion and weed control
•     Assess whether landscapes can still meet the intended site use objectives while
      modifying the aesthetic standard and/or applying less maintenance
•     Match maintenance standards to site objectives in the design stage
•     Construct walkways so as to prevent weed intrusion; and
•     Plant vegetation that will encourage the presence of beneficial insects and birds

City of Santa Barbara IPM Strategy    Page 22
XII.    Contractors

When a Department enters into a new contract or extends the term of an existing
contract that authorizes a contractor to apply pesticides to property, the contract shall
obligate the contractor to comply with all provisions of this IPM Policy. In addition, the
contractor shall submit to the City an IPM implementation plan that lists:
• The types and estimated quantities, to the extent possible, of pesticides that the
    contractor may need to apply to property during its contract;
• Outline actions the contractor will take to meet the IPM Policy to the extent feasible;
• Identify the primary IPM contact for the contractor.

A contractor, or department on behalf of a contractor, may apply for any exemption
authorized under the exemptions section of this policy.

City of Santa Barbara IPM Strategy    Page 23
XIII.   Precautionary Principle

It is the policy of the City to adopt, properly implement and practice low risk/least
hazardous Integrated Pest Management with the goal of immediately minimizing the risk
of pesticide exposure to staff, the environment, and the public. This policy is based on
what is referred to as the ‘Precautionary Principle’ of pest management. The guiding
principles in this policy are based on the following: (1) No pesticide is free from risk or
threat to human health, (2) all reasonable alternative measures of pest management
have been attempted and have been shown, and documented in writing, to be
unsuccessful, and (3) pesticides suspected of being in conflict with the mission and
goals of this policy shall not be used without an exemption, or until it is determined that
a specific product is safe for use around sensitive individuals (i.e. children, elderly,
asthmatics, etc.).

The Precautionary Principle should guide decision-making processes when it comes to
the health and safety of staff and public. All aspects of the program will be in
accordance with federal and state laws and regulations and county policies. All
departments within the City must conform to the IPM Strategy.

City of Santa Barbara IPM Strategy    Page 24
Addendum A ................................................................Material Exception Request for
                                                                           Pesticide Application

Addendum B ................................................................Notice of Pesticide Application

Addendum C………………………………………………Monthly Alternative Use Report
(English Version)

Addendum D………………………………………………Monthly Pesticide Use Report
(English Version)

City of Santa Barbara IPM Strategy             Page 25
                                             ADDENDUM A
                               MATERIAL EXCEPTION REQUEST FOR
                                      PESTICIDE APPLICATION
Dept:                    IPM Coordinator:                        Phone:
Pesticide Applicators (company) Name:                     Phone:
Site Name:                                                Date:
Name of Product:
(Attach the product label and MSDS to this form)
Product exemption request is:
     #        One time exemption
     #        Programmatic exemption
Product type:
     #        Herbicide
     #        Insecticide
     #        Fungicide
     #        Other
     #        Ornamental
     #        Turf
     #        Golf
     #        Street Tree
     #        Park Tree
     #        Right of Way
     #        Vector control
     #        Vertebrate pest
Describe the management goals and objectives for this site.

Describe the pest problem.

What is the damage threshold for this pest at this site?

What monitoring of the pest and potential predators (where applicable) has been conducted and what control methods have been
previously used at the site?

Describe how the product would be applied including frequency, concentration, and method of application.

What non-target impacts do you anticipate?

How does the use of this product help achieve the site management goals and objectives? Note if this is curative or preventative.

How will the effectiveness of this product be monitored? Include your expected results and indicators of success.

Describe the site conditions. Please note if this is a restricted access area, within 0 feet from a creek or body of water, subject to
runoff or in a designated “Pesticide Free Zone.”

Describe the alternatives considered and detail why they were eliminated. Include an analysis of why this is the most
environmentally prudent option and why a less-hazardous chemical, non-chemical option, or taking no action is not feasible.

•    Exemption Request                               # Approved       # Denied

If denied, give the reason:

If approved, follow the attached best management practices.

                     Department IPM Coordinator                                                    City IPM Coordinator

City of Santa Barbara IPM Strategy                         Page 26

                                     NOTICE OF
Day                                         Date

The material(s) being applied is (are):

Product Toxicity Category:
                                                             (Signal Word)
Target Pest:
Area Treated:
                                     (Attach map if necessary)

Signs will remain 72 hours after pesticide application.
If you have questions, please call us at:


City of Santa Barbara IPM Strategy      Page 27

 Location                                        Supervisor                           Month             Year


         Location              Approximate Sq.      Time/Hours Per Person   Type of Method and Target     Comments
                                     Ft.                                              Pest

City of Santa Barbara IPM Strategy        Page 28
                      CITY OF SANTA BARBARA
                      •    MONTHLY PESTICIDE USE REPORT
                                                              (Due by the 1st of every month)
 Location                                    Supervisor                                 Month                Year

      Date/Park            Product &     EPA Reg.    How        Specific Area    Rate        Total     Weather      Applicator (Print)
                          Manufacturer      #       Applied   Treated & Target              Product   Conditions
                                                                    Pest                     Used






City of Santa Barbara IPM Strategy        Page 29

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